Bradley Birkenfeld is a former Swiss banker who helped the Internal Revenue Service (IRS) recoup billions of dollars in tax revenues after exposing the largest tax fraud in U.S. history. Yet it was Birkenfeld who served 40 months at the Schuylkill Federal Correctional Institution in Minersville, Pennsylvania, while his bosses who orchestrated the fraud and the wealthy investors who cheated the U.S. government never faced any jail time. Birkenfeld's boss, Christian Bovay, conceived the scam that Birkenfeld participated in by which UBS would charge a three percent management fee to its wealthy clients in exchange for helping them to evade paying taxes by placing it securely in one of the bank's secret off-shore accounts. Birkenfeld would make clients more money by investing, often in weapons manufacturers. Then when the clients needed their money, UBS would lend it back at a reasonable interest rate. Birkenfeld wrote in Lucifer's Banker that "UBS was making a fee for holding the guy's cash in the first place, then making another fee for loaning him his own damn money! And guess what? That guy's happy! He's getting his deal done, and he's still doing it with tax-free cash! I couldn't believe it, and you know what? It worked, over and over again." On October 5, 2005, Birkenfeld resigned from UBS and became an internal whistleblower. After a company review of its malpractice turned into a whitewash, Birkenfeld sued UBS.
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